Overview
A global technology organization is seeking a Global Senior Tax Manager to lead tax planning, international operations, cash repatriation, mergers and acquisitions, and tax research across more than 30 global subsidiaries. This role is a key member of the Finance Management team and requires extensive experience managing global tax strategy in a fast-paced, high-growth environment.
Responsibilities
- Maintain a deep understanding of the business and financial operations.
- Assist with International Tax Computations including Foreign Tax Credits (FTC), GILTI, FDII, Subpart F, BEAT, and Pillar Two in accordance with ASC 740 (Accounting for Income Taxes).
- Lead the tax workstream for all M&A activities, including due diligence, integration, and post-acquisition restructuring.
- Develop and implement tax-efficient deal structures such as asset vs. stock deals, Section 338(h)(10) elections, and tax-free reorganizations.
- Develop and execute tax-efficient cash repatriation strategies from foreign subsidiaries considering earnings and profits, basis, foreign tax credits, and withholding tax implications.
- Drive transfer pricing strategy and execution, including development and maintenance of intercompany agreements and policies aligned with business operations.
- Oversee global transfer pricing documentation including Master File, Local Files, and Country-by-Country Reporting (CbCR).
- Monitor and assess the impact of global tax reforms such as OECD Pillar Two initiatives and develop proactive strategies.
- Conduct in-depth tax research on complex federal, state, and international tax issues, especially those impacting the software industry and M&A transactions.
- Manage federal, state, and international income tax audit defense, including preparation of responses and supporting documentation.
- Oversee international tax compliance filings (e.g., Forms 5471, 8858, 8865, 8990, 8991, 8992, 8993, 1118) and ensure proper integration with the US consolidated return.
- Participate in cross-functional projects to support business decision-making from a tax perspective.
Requirements
- 8–10 years of experience in Big 4 accounting firms or law firms with corporate tax environments.
- Bachelor's degree in Accounting, Finance, or a related field.
- Strongly desired: Juris Doctor (JD) often complemented by an LL.M. in Taxation; Certified Public Accountant (CPA) license or active bar membership (Attorney).
- Proven experience leading tax aspects of complex M&A transactions, including due diligence, structuring, modeling, negotiation of tax indemnities, and post-acquisition integration.
- Deep expertise in US international tax provisions such as GILTI, FDII, BEAT, Subpart F, Section 861, and FTCs.
- Experience with multi-jurisdictional tax planning, cross-border transactions, and global tax reform initiatives (e.g., OECD Pillar One and Pillar Two).
- Significant experience developing, implementing, and defending global transfer pricing policies and documentation.
- Proficiency in Microsoft Excel modeling for complex tax scenarios, M&A valuations, repatriation planning, and tax forecasting.
- Executive presence and strong communication skills to collaborate with executive leadership.
- Excellent written and verbal communication skills, including drafting clear and technically sound tax memoranda, presentations, and reports.
- Strong strategic thinking and problem-solving abilities to analyze complex business scenarios and develop innovative tax solutions.
- Experience in the software or high-tech industry is highly advantageous, with knowledge of SaaS revenue models, software development capitalization, and intellectual property tax implications.
Compensation & Benefits
- Salary range: $123,250 to $207,000 USD, determined based on qualifications and experience.
- Continuous professional development and product training.
- Inclusive culture with opportunities to join employee groups.
- Comprehensive benefits supporting health, financial security, and work-life balance.
- Employee stock purchase plan (ESPP).
Location
Additional Information
- The organization does not conduct interviews via email or text and will never request sensitive documents such as social security numbers or banking information before the first day of employment.
- Equal opportunity employer committed to diversity and inclusion.
- Accommodations are available for candidates with disabilities during the interview process upon request.